United States securities and exchange commission logo
October 26, 2023
Richard Rychlik
VP, Corporate Controller
Armata Pharmaceuticals, Inc.
5005 McConnell Avenue
Los Angeles, CA 90066
Re: Armata
Pharmaceuticals, Inc.
Form 10-K for the
fiscal year ended December 31, 2022
Form 10-Q for the
quarterly period ended June 30, 2023
File No. 001-37544
Dear Richard Rychlik:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
74
Results of Operations, page 78
1. Given the significance
of your research and development (R&D) expenses for the periods
presented, please
revise your future disclosures to quantify such expenses by product
candidate and provide a
detailed analysis of the changes therein. To the extent you are
unable to track such
costs at that level, revise to disclose that fact and identify the reasons
why. For all amounts
that are not allocated by product candidate, provide a breakdown by
type or nature of
expense, such that the total reconciles to the research and development
line item on the face
of your statement of operations.
Richard Rychlik
Armata Pharmaceuticals, Inc.
October 26, 2023
Page 2
Form 10-Q for the quarterly period ended June 30, 2023
Controls and Procedures, page 31
2. You disclose that you did not identify any change in your internal
control over financial
reporting that occurred during your latest fiscal quarter that has
materially affected, or is
reasonably likely to materially affect, your internal control over
financial reporting, but
that because your "evaluation is ongoing and because of its ongoing
nature, there can be
no assurance that we will not identify any change that would
materially affect, or be
reasonably likely to materially affect, our internal control over
financial reporting." We
note this same qualifying language is included in the Form 10-Q for
the quarter ended
March 31, 2023. Please revise your future disclosures to comply with
the the requirements
of Item 308(c) of Regulation S-K by providing a clear positive or
negative conclusion that
omits similar such qualifying language and to clearly disclose any
material changes
identified.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Jenn Do at 202-551-3743 or Kevin Vaughn at 202-551-3494
with any
questions.
FirstName LastNameRichard Rychlik Sincerely,
Comapany NameArmata Pharmaceuticals, Inc.
Division of
Corporation Finance
October 26, 2023 Page 2 Office of Life
Sciences
FirstName LastName